**SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST** (in accordance with 40 CFR Part 51

- App. V) SI P Submitted by : Pennsylvania Department of Environment al Protection Date Submitted: December 3 , 2014 Subject: Redesignation R equest and Maintenance Plan for the Johnstown 1997 Annual and the 2006 24

- Hour Fine

Particulate Matter ( PM 2.5 ) Nonattainment Area Completeness Review Completed by : Rose Quinto Date Completed: January 13, 2015 **Administrative Materials ACCEPTABLE** 

**EPA REQUIREMENT STATE SUBMITTAL**  **( X)**  1. A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. 1. Submittal l etter dated December 3 , 2014 from PADEP Acting Secretary Dana K. Aunkst to EPA Region 3 Regional Administrator Shawn M Garvin. Submittal letter was received on December 4 , 2014

. X

2. Evidence that the State has adopted the plan in the State code or body

of regulations; or issued the permit, order, consent agreement in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date. 2. Not applicable. (Not a regulatory change

- the submittal is a request for redesignation, accompanied by a maintenance plan, and a request for approval of the attainment ye ar inventory ).

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 3. The submittal letter states that all applicable procedural requirements o f the State’s laws and constitution were followed in conducting and completing the issuance of the plan. X4. A copy of actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication of the chan ges made to the existing approved plan, where applicable. The submittal shall be a copy of the official State regulation/document signed, stamped, dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date of the regulation/document shall, whenever possible, be indicated in the document itself. 4. Not applicable , see 2 above.

5. Evidence that the State followed all of the procedural requirements of the State's laws and constitution in co nducting and completing the adoption/issuance of the plan. 5. The submittal include s documentation showing that the State followed State procedural and administrative requirements in issuing the plan. X

6. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date of publication of such notice. 6. The submittal include s a copy of the n otice of public hearing and public comment period that was published in the Pe nnsylvania Bulletin on Oct ober 4 , 2014 , and in the Johnstown Tribune

- Democrat on October 3 , 2014

. X

7. Certification that public hearings were held in accordance with the information provided in the public notice and the State's laws and constitution, if applicable. 7. A pub lic hearing was scheduled in acc ordance with the public notice on November 5, 2014. X

8. Compilation of public comments and the State's response thereto. 8. No comments were received during the public comment period. X**Technical Materials**
**EPA R EQUIREMENT**  **STATE SUBMITTAL**

1. Id entification of all regulated pollutants affected by the plan. 1. Chapter 1 o f the Maintenance Plan show s that nitrogen oxides (N Ox ) , sulfur oxides ( SO 2 ), PM 2.5 , ammonia (NH 3 ), and volatile organic compounds ( VOC ) are the pollutants affected by the plan. X

2. Id entification of the locations of affected sources including the EPA attainment/nonattainment designation of the locations and the status of the attainment plan for the affected area(s). 2. R ed esignation affects the Johnstown 1997 annual and 2006 24

- hour PM 2.5 nonattainment area comprised of Cambria and In diana Counties , PA. EPA made a Clean Data Determination that the Area had attained the 1997 annual PM 2.5 national ambient air quality

standard (NAA QS ) on September 25, 2009; and the 2006 24

- hour PM 2.5 NAAQS on March 29, 2012 , thereby suspending the requirement for an attainment plan. X

3. Quantification of the changes in plan allowable emissions from the affected sources; estimates of chang es in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision. 3. The submittal provides 2007 actual emissions from point, area, nonroad, and on

- road source categories as the attainment ye ar inventory , which may not be exc eeded during the period of the maintenance plan. Projection inventorie s were calculated to show that the attainment year emissions level will be below 2007 levels. X

4. The State's demonstration that the national ambient air quality standards, prevention of significant deterioration increments, reasonable further progr ess demonstration, and visibility , as applicable, are protected if the plan is approved and implemented. 4. PADEP submitted a demonstration that shows that emissions of PM 2.5 and its precursors will not exceed the level of the attainment inventory during the period of the Maintenance Plan. Projected interim year 2017 and end year 2025 emissions inventories, based on permanent and enforceable measures, are below the 2007 inve ntory , which assures the NAAQS is maintained. X

5. Modeling information requ ired to support the proposed revision, including input data, output data, models used, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information rel evant to 5. Not applicable.the determination of adequacy of the modeling analy sis. 6. Evidence, where necessary , that emission limitations are based on continuous emission reduction technology

. 6. Not applicable.

7. Evidence that the plan co ntains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary , to ensure emission levels. 7. Based on permanent and enforceable measures, Pennsylvania projects emissions inventories for int erim year 2017 an d end ye ar 202 5 that do not exceed the 2007 attainment ye ar inventory , which demonstrate attainment throughout the entire maintenance period. X

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8

. The Maintenance Plan i dentifie s when and what c ontingency

measures may be implemented if the Area violates or exceeds the 2006 24

- hour PM 2.5 NAAQS after redesignation of the Area

. These measures are intended to expeditiously bring the A rea back in to attainment of the NAAQS

. X

9. Special economic and technological justifications required by any applicable EPA policies. (I f a policy is not appropriate, explain why .) 9. Not applicable.

10. A Section 107 request must be accompanied by a maintenance p lan demonstrating maintenance to the relevant NAAQS for at least 10 y ears after redesignation. 10. The redesignation request was accompanied by a Maintenance Plan that w as received from PADEP on December 4 , 2014 , which shows maintenance of the 1997 annual and the 2006 24

- hour PM 2.5 NAAQS for 10 y ears after redesignation (through 2025). X